1. Introduction
This is the privacy policy of LibertySpace Ltd. It tells you how we process personal data. Please read the following carefully to understand how we will collect and use your personal data.
If you have any comments on this privacy policy, please email them to: [email protected]
2. Who we are and how to contact us
LibertySpace Ltd is the controller and responsible for your personal data. Our address is Sybrig House, 2 Ridge Way, Dalgety Bay KY11 9JN.
Our site addresses are www.flourmilldundee.co.uk and www.libertyspace.co.uk.
We can also be contacted at [email protected].
3. Personal data we process
We may collect, use, store and otherwise process the following kinds of personal data about you:
- identity data including name, title and date of birth;
- contact information including address, billing address, email address and telephone number;
- payment informationincluding bank account and payment card details;
- transaction informationincluding details about payments to and from you and details of services you have purchased from us;
- information you put into forms, surveys, reviews or the chat function on our websites;
- record of any correspondence between us;
- information regarding office space requirements;
- details of your visits to our websites and the resources you use;
- technical information such as your IP address, browser information and operating system information;
- information about how you use our websites including browsing actions and patterns; and
- your preferences in receiving marketing from us and your communication preferences.
We do not collect any special categories of personal data (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
4. Please keep us informed of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
5. If you do not provide personal data
Where we need to collect personal data by law, or under a contract we have with you, and you fail to provide the requested data, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
6. How is your personal data collected
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your personal data for example by filling in forms or by corresponding with us by post, phone, email, website chat function or otherwise, or when you visit our offices in person.
- Automated technologies or interactions. As you interact with our websites, we will automatically collect technical and usage data about you. We collect this personal data by using cookies and other similar technologies. Please see our cookies policy for further details.
- Third parties. We will receive personal data about you from third parties as set out below:
- Third party providers of cookies and other similar technologies which provide analytical or advertising functions for our websites may provide us your technical and usage data. Please see our cookies policy for further information.
- Office space brokers may provide us with your identity and contact information as well as any information you have provided to them regarding your office space requirements.
7. Purposes for which we use your personal data
We use your personal data to:
- enter into and carry out contracts with you and, if necessary, enforce any contract;
- process your transactions/orders, including managing payments, fees and charges and collecting and recovering money owed to us;
- manage our relationship with you, including notifying you about changes to our terms or privacy policy and asking you to leave a review or take a survey;
- enable you to complete reviews/surveys;
- administer and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
- deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising;
- improve our websites and the user experience, products/services, marketing, customer relationships and experiences;
- provide you with information you have requested (including information about our charges);
- protect against fraud or credit risks;
- comply with any legal, regulatory, tax, accounting or reporting requirements; and
- tell you about other goods and services that might interest you.
Direct marketing
You may receive marketing communications from us if you have requested information from us or rented office space from us and you have not opted out of receiving that marketing.
You can ask us to stop sending you direct marketing messages at any time by contacting us.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.
8. Our legal basis of processing
We will comply with data protection laws in processing your personal data. We will only process your personal data if at least one of the following bases applies:
- you have given consent to the processing of your personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which we are subject;
- processing is necessary to protect the vital interests of you or of another person; and/or
- processing is necessary for the purposes of legitimate interests pursued by us or by a third party, except where such interests are overridden by your fundamental rights and freedoms which require protection of personal data.
Our legitimate interests
Where we rely on legitimate interests to process your personal data, the legitimate interest will be one of the following:
- enforcing our contractual rights and recovering payments due to us;
- keeping our records updated and understanding how customers use our products/services;
- conducting and managing our business and developing our products/services;
- running and protecting our business, administration and IT functions, security and preventing fraud;
- managing customer relationships and obtaining feedback;
- business reorganisation or group restructuring;
- protecting our and other people’s property, safety or rights;
- informing our marketing strategy and direct marketing; and
- keeping our websites updated and relevant and understanding use of our websites.
We may process personal data using more than one lawful ground depending on the purpose for which we are using personal data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data for a specific purpose.
9. Cookies
Our websites use cookies and other similar technologies. For more information, please see our cookies policy.
You can change your browser settings to prevent setting of cookies or to notify you each time a cookie is set. Please note however, that by blocking or deleting cookies you may not be able to take full advantage of our websites.
10. International transfers of your data
We may transfer personal data outside the UK. For example some of our service providers are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
11. How long do we keep your data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We conduct an annual review in line with the above criteria to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it.
12. Disclosing your information
We may share your personal data with the parties set out below for the purposes set out in section 7 (Purposes for which we use your personal data).
- Our third party service providers (for example in respect of payment processing, our e-mail and IT systems and websites as well as advertising and marketing). Currently our service providers include Microsoft, Dropbox and HubSpot, Ionos, Mailchimp, Yardi Medusa, WorldPay, WordPress and Yardi Kube.
- If we want to sell, transfer or merge our business or our company (entirely or in part), we can disclose it to third parties. Alternatively, we may seek to acquire other businesses or merge with them.
- We can disclose it to other businesses in our group.
- Law enforcement authorities and regulators
- Credit reference and fraud prevention agencies
- Debt collection and tracing agencies
- Courts, tribunals and hearings
- Professional advisers
We require third parties to treat your personal data in accordance with the law.
13. Your rights
You can ask us not to use your data for direct marketing. You can do this by contacting us at any time at [email protected].
Under certain circumstances, you have the right under data protection laws to:
- request access to your personal data;
- request deletion of your personal data;
- request correction of your personal data;
- request that your personal data be transferred to another person (data portability);
- request restriction of processing;
- withdraw consent;
- object to processing of your personal data; and
- complain to a supervisory authority.
You also have rights with respect to automated decision-making and profiling as set out in section 16 below.
To exercise any of the foregoing rights or if you have any other questions about our website or this privacy policy, please contact us at [email protected].
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
14. Links to other sites
Please note that our terms and conditions and our policies will not apply to third party websites that you get to via a link from our site. We have no control over how your data is collected, stored or used by such other websites and we advise you to check the privacy policies of any such websites.
15. Changes
If we change our privacy policy, we will post the changes on this page. We may also email you.
15. Automated Decision-Making and Profiling
Unless required by law or where you have given us your explicit consent, if we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge such decisions, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.
